Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
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Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
Writ petition challenging reopening of assessment u/s 147 for income chargeable u/s 5(2) rejected. Petitioner failed to establish with documentary evidence husband's non-resident Indian status and genuineness of sources of funds transferred from NRE account to domestic account. Court reluctant to interfere in assessment orders under Article 226 when effective alternative remedy available, especially involving disputed questions of fact. Petitioner granted liberty to file appeal within three weeks from order copy receipt, without limitation objection, subject to compliance with appeal conditions including pre-deposit, if any. Merits not examined, observation limited to maintainability of writ petition.
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